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11 October 2013 APFF Roundtable, 2013-0495651C6 F- Revenu fractionné-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) streaming of non-split income to child discretionary beneficiary and split income to mother A discretionary family trust with Father, Mother and a 15-year old Child as beneficiaries, holds a building with two premises – the first leased to an arm's length tenant; and the second, to a professional corporation of Father and Mother. ...

After noting that the creation of a usufruct governed by the C.c.f. did not give rise to a deemed trust under s. 248(3), CRA stated (TaxInterpretations translation): … the Taxpayer is deemed to have disposed of the Immovable for consideration equal to its FMV and that her children were deemed to have acquired the property for the same amount, all in accordance with the provisions of paragraphs 69(1)(b) and (c). ...

After noting that the creation of a usufruct governed by the C.c.f. did not give rise to a deemed trust under s. 248(3), CRA stated (TaxInterpretations translation): … the Taxpayer is deemed to have disposed of the Immovable for consideration equal to its FMV and that her children were deemed to have acquired the property for the same amount, all in accordance with the provisions of paragraphs 69(1)(b) and (c). ...

For the purposes of the limitation under subsection 135(2), the amount that may be deducted by the taxpayer for the year is $20 million, being the lesser of: (a) all payments referred to in subsection 135(1), or $23 million ($17 million + $6 million); and (b) the portion of the taxpayer's income attributable to business done with members, being $20 million. …$3 million ($23 million- $20 million) can be carried forward to subsequent years under subsection 135(2.1). ...

20 March 2013 Internal T.I. 2013-0480201I7 F- Montants forfaitaires- XXXXXXXXXX-- summary under Qualifying Amount Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.2- Subsection 110.2(1)- Qualifying Amount portion of wage discrimination award that related to loss of salary (based on days’ worked) would be qualifying amount In discussing the treatment of lump sums paid to federal employees following a finding by the Human Rights Tribunal that a discriminatory practice had been committed at their workplace and pursuant to a settlement agreement concluded with the Treasury Board, CRA stated: [I]f the amounts paid … are intended to compensate for a loss of Workers' salaries, they meet the definition of "qualifying amount" under subsection 110.2(1). ...

., the mark-up covers other costs such as employment benefits – and that whether more than that level of markup would result in an offsetting deduction in computing the FAPI of FA "depends on the proper determination of the related profit to be attributed to the activities of the relevant personnel. ...

. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...

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. … In Johanne Maurice v. The Queen, 2001 DTC 3710, Mrs. Maurice was receiving amounts in her capacity as a tutor for home help services she personally provided to her mentally incompetent daughter, a minor. ...

CRA responded: S3-F6-C1 … paragraph… 1.71… indicates that such loss consolidation arrangements could be undertaken by parties that are related but not affiliated (as well as parties that are both related and affiliated and parties that are affiliated but not related). ...